0211.003 / 17 / 00061525.DOC 2

BERGESON & CAMPBELL, P.C. 

1203 Nineteenth Street, NW | Suite 300 | Washington, DC | 20036-2401 | tel 202.557.3800 | fax 202.557.3836 | web www.lawbc.com

Christopher R. Bryant direct dial 202.557.3818 e-mail cbryant@lawbc.com

June 2, 2010 

Via E-Mail

Mr. Charles French 

Metals and Minerals Group 

Sector Policies and Program Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

109 T.W. Alexander Drive 

Mail Code: D243-02 

Research Triangle Park, NC 27709 

 Re: Meeting with RSR Corporation

Dear Mr. French: 

 On behalf of RSR Corporation (RSR), I write to thank you for meeting with us on 

May 27, 2010, to discuss the extraordinary reductions in emissions of lead and other hazardous 

air pollutants that RSR has achieved at its Quemetco, Inc. (Quemetco) subsidiary in City of 

Industry, California. We found the meeting productive and informative and very much 

appreciate you taking the time to discuss this important technology with us. 

 Quemetco’s installation of a Wet Electrostatic Precipitator (WESP) and a 

Regenerative Thermal Oxidizer (RTO) has yielded dramatic reductions in air emissions from its 

operations. For example, prior to the installation of the WESP and RTO, Quemetco emitted 

614.95 pounds of lead annually. After installing the technology, lead emissions plummeted to 

1.22 pounds per year -- a 99.8 percent reduction. The table below highlights equally impressive 

reductions in other air pollutants at the Quemetco facility. 

Pollutant Pre-WESP/RTO 

Emissions 

(lbs/year) 

Post-WESP/RTO 

Emissions 

(lbs/year) 

Percent Reduction 

(%) 

Arsenic 96.01 1.59 98.3 

1,3-butadiene 2,024.88 16.49 99.2 

Cadmium 6.55 0.53 91.9 

Chromium (VI) 0.33 0.06 81.8 

Dioxins 0.0004 3.83 X 10-7 99.9 

Benzene 1,653.07 681.09 58.8 
Mr. Charles French 

June 2, 2010 

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BERGESON & CAMPBELL, P.C. 

Pollutant Pre-WESP/RTO 

Emissions 

(lbs/year) 

Post-WESP/RTO 

Emissions 

(lbs/year) 

Percent Reduction 

(%) 

Lead 614.95 1.22 99.8 

Formaldehyde 5,815.93 179.36 96.9 

Acetaldehyde 3,996.93 330.69 91.7 

Nickel 7.07 0.18 97.5 

 RSR’s primary goal in installing this technology was to ensure consistent 

compliance with the revised National Ambient Air Quality Standard (NAAQS) for lead and to 

invest in its ability successfully to operate in arguably the most challenging air district in the 

nation -- the South Coast Air Quality Management District. RSR could have chosen more 

conventional -- and less costly -- technology to achieve these ends. And there was appreciable 

risk associated with the installation of the WESP/RTO technology; this particular configuration 

and approach had never been successfully implemented before at a secondary lead smelter. 

After considerable research and analysis, however, the company chose the WESP/RTO approach 

because it believes the technology will achieve world class reductions in emissions of lead and 

other hazardous pollutants from its operations. 

 The results speak for themselves. The technology is even more effective than the 

company originally hoped. The substantial reductions in emissions listed above means that the 

cancer risk attributable to emissions of these compounds was slashed by approximately 87 

percent to 2.88 cancer cases in one million exposed individuals over a 70-year evaluation period. 

Because of the overwhelming success of the technology, RSR intends to install the WESP/RTO 

technology at its Indianapolis, Indiana, facility this year and at its Middletown, New York, 

facility in 2011. 

 Meaningful reductions in the residual risks posed by secondary lead smelters are 

achievable. RSR has proven this with the successful installation of the WESP/RTO technologies 

at its operations. As EPA develops the rulemaking for the Residual Risk Maximum Achievable 

Control Technology (MACT) rule for secondary lead smelters, we thus strongly urge EPA to 

evaluate fully the potential that this technology can bring to bear. EPA need look no further for 

its MACT floor. 

 As you requested, appended are the Quemetco fenceline monitoring data from 

2007 (pre-WESP/RTO) and 2009 (post-WESP/RTO). After you have had time to review the 

data, we would welcome the opportunity to visit with you again to answer any questions and to 

discuss the data in more detail. I will be in touch shortly to schedule a follow-up meeting. 
Mr. Charles French 

June 2, 2010 

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BERGESON & CAMPBELL, P.C. 

 Once again, I want to thank you for meeting with us. 

Sincerely, 

Christopher R. Bryant 

Attachment 

cc: Mr. Robert E. Finn (w/attachment) (via e-mail) 

Mr. John A. De Paul (w/attachment) (via e-mail) 

Mr. Homer P. Hine (w/attachment) (via e-mail) 

Mr. Mike Buckantz (w/attachment) (via e-mail)